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I throughout the State of California. The alleged violations of the law, hereinafter described, have <br /> 2 been carried out within said San Joaquin County and elsewhere throughout the State of California. <br /> 3 The alleged actions of the Defendants and each of them,jointly and separately, as set out below, are _ <br /> 4 in violation of the law and public policy of the State of California. Unless enjoined and restrained by <br /> 5 an order of this court, the Defendants will continue to retain the means to engage in unlawful action <br /> 6 and practices and courses of conduct set out below. <br /> 7 DEFENDANTS <br /> 8 4. Defendant CITY OF LATHROP, a business of unknown type of organization, is, and <br /> 9 at all times relevant herein was, engaged in the business of WATER TREATMENT SYSTEM/CITY <br /> 10 OF LATHROP, located at 2112 E. LOUISE AVENUE,LATHROP, CALIFORNIA. <br /> 11 5. Defendant DOES ONE through TWENTY is connected and responsible for the acts <br /> 12 complained of below. Their real names are unknown at this time, and the People will amend this <br /> 13 complaint at a later date when the true identities of DOES ONE through TWENTY are discovered. <br /> 14 6. Whenever in this Complaint reference is made to any act of Defendants, such <br /> 15 allegation shall be deemed to mean that Defendants and their officers, agents, employees, or <br /> 16 representatives, did or authorized acts while actively engaged in the management, direction, or <br /> 17 control of the affairs of said Defendants, and while acting within the course and scope of their duties. <br /> 18 7. All Defendants at all times acted as agents of one another. With regard to the conduct <br /> 19 and omissions alleged in this Complaint, each of the Defendants ratified the actions of the other <br /> 20 Defendants. <br /> 21 FIRST CAUSE OF ACTION <br /> 22 <br /> VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 23 (HAZARDOUS WASTE CONTROL ACT) <br /> 24 8. Plaintiff is informed and believes and based on such information and belief alleges <br /> 25 that beginning at an exact date that is unknown to Plaintiff, but within five (5)years prior to the filing <br /> 26 of this Complaint(CCP §338.1),Defendants engaged in acts in violation of Health and Safety Code <br /> 27 §25100 et seq., including but not limited to the following: <br /> 28 a. Disposed or caused the disposal of a hazardous or extremely hazardous waste <br /> -2- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL,PENALTIES,AND OTHER RELIEF <br />